COUNTDOWN TO 2023 2023 - WHO REPORT ON GLOBAL TRANS FAT ELIMINATION 2020 - World Health Organization
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Countdown to 2023: WHO report on global trans-fat elimination 2020 ISBN 978-92-4-001017-8 (electronic version) ISBN 978-92-4-001018-5 (print version) © World Health Organization 2020 Some rights reserved. This work is available under the Creative Commons Attribution NonCommercial-ShareAlike 3.0 IGO licence (CC BY-NC-SA 3.0 IGO; https://creativecommons.org/licenses/by-nc-sa/3.0/igo). Under the terms of this licence, you may copy, redistribute and adapt the work for non- commercial purposes, provided the work is appropriately cited, as indicated below. In any use of this work, there should be no suggestion that WHO endorses any specific organization, products or services. The use of the WHO logo is not permitted. If you adapt the work, then you must license your work under the same or equivalent Creative Commons licence. If you create a translation of this work, you should add the following disclaimer along with the suggested citation: “This translation was not created by the World Health Organization (WHO). WHO is not responsible for the content or accuracy of this translation. The original English edition shall be the binding and authentic edition”. Any mediation relating to disputes arising under the licence shall be conducted in accordance with the mediation rules of the World Intellectual Property Organization (http://www.wipo.int/amc/en/mediation/rules/). Suggested citation. Countdown to 2023: WHO report on global trans-fat elimination 2020. Geneva: World Health Organization; 2020. Licence: CC BY-NC-SA 3.0 IGO. Cataloguing-in-Publication (CIP) data. CIP data are available at http://apps.who.int/iris. Sales, rights and licensing. To purchase WHO publications, see http://apps.who.int/bookorders. To submit requests for commercial use and queries on rights and licensing, see http://www.who.int/about/licensing. Third-party materials. If you wish to reuse material from this work that is attributed to a third party, such as tables, figures or images, it is your responsibility to determine whether permission is needed for that reuse and to obtain permission from the copyright holder. The risk of claims resulting from infringement of any third-party-owned component in the work rests solely with the user. General disclaimers. The designations employed and the presentation of the material in this publication do not imply the expression of any opinion whatsoever on the part of WHO concerning the legal status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. Dotted and dashed lines on maps represent approximate border lines for which there may not yet be full agreement. The mention of specific companies or of certain manufacturers’ products does not imply that they are endorsed or recommended by WHO in preference to others of a similar nature that are not mentioned. Errors and omissions excepted, the names of proprietary products are distinguished by initial capital letters. All reasonable precautions have been taken by WHO to verify the information contained in this publication. However, the published material is being distributed without warranty of any kind, either expressed or implied. The responsibility for the interpretation and use of the material lies with the reader. In no event shall WHO be liable for damages arising from its use.
CONTENTS ACKNOWLEDGEMENTS III 3. Eastern Mediterranean 17 Current situation 17 ACRONYMS IV New in the past year 17 FOREWORD V 4. Europe 19 EXECUTIVE SUMMARY VII Current situation 19 I. INTRODUCTION 1 New in the past year 20 II. GLOBAL PROGRESS 3 5. South-East Asia 22 Current situation 22 1. Country policies 3 New in the past year 22 Current situation 3 New in the past year 7 6. Western Pacific 24 Current situation 24 2. Support for reformulation 8 New in the past year 24 Current situation 8 New in the past year 8 IV. GLOBAL CHALLENGES, OPPORTUNITIES AND PRIORITIES 27 3. Global resources and support for policy action 9 V. CONCLUSION AND RECOMMENDATIONS Current situation 9 FOR ACTION 28 New in the past year 9 REFERENCES 30 III. PROGRESS BY REGION 11 ANNEX 1 TFA burden and status of TFA policies by 1. Africa 11 country, ranked by proportion of coronary Current situation 11 heart disease deaths due to TFA intake 32 New in the past year 11 2. Americas 13 ANNEX 2 Updated methodologies used to estimate Current situation 13 TFA burden by country for this report 44 New in the past year 13 ACKNOWLEDGEMENTS This progress report was prepared by the World Health Organization (WHO) Department of Nutrition and Food Safety, in close collaboration with Resolve to Save Lives (an initiative of Vital Strategies). WHO acknowledges the great support and valuable contributions of colleagues at Resolve to Save Lives. WHO also recognizes the valuable contributions made by other collaborators and partners working together to eliminate industrially produced trans-fatty acids (TFA) from the global food supply. WHO wishes to acknowledge Dr Ashkan Afshin and his team at the Institute for Health Metrics and Evaluation for providing data and technical expertise. Acknowledgement is also made of WHO regional and country office colleagues, including those from the WHO European Office for the Prevention and Control of Noncommunicable Diseases in Moscow, and their national counterparts, in making tremendous efforts to validate country data and information on the status of TFA-related policies. Special thanks are due to Member States, which are committed and are taking concrete actions to achieve the global target of TFA elimination by 2023. iii
ACRONYMS ANVISA Agência Nacional de Vigilância Sanitária (Brazil’s IHME Institute for Health Metrics and Evaluation National Agency of Sanitary Surveillance) NAFDAC Nigerian National Agency for Food and Drug CHD coronary heart disease Administration and Control EAEU Eurasian Economic Union NCD noncommunicable disease EEA European Economic Area PAHO Pan-American Health Organization EU European Union PHO partially hydrogenated oils GBD Global Burden of Disease SFDA Saudi Arabian Food and Drug Administration GCC Gulf Cooperation Council SFA saturated fatty acids GSO GCC Standardization Organization TFA trans-fatty acids IFBA International Food and Beverage Alliance WHO World Health Organization iv
FOREWORD COUNTDOWN TO 2023: WHO REPORT ON GLOBAL TRANS FAT ELIMINATION 2020 Noncommunicable diseases (NCDs) – including heart disease, stroke, cancer and diabetes – kill 41 million people worldwide every year. Cardiovascular disease is the main killer, accounting for nearly half of all NCD deaths. Many of these deaths are in people under 70 years of age, and most occur in low- and middle-income countries. The World Health Organization (WHO) is committed to supporting countries to achieve the Sustainable Development Goal objective of reducing premature deaths from NCDs by one third by 2030. Diet-related risk factors are a major driver of preventable deaths due to cardiovascular disease. Industrially produced trans-fatty acids (TFA), which are still used in some countries as an ingredient in fried food, deep-fried food, baked goods and spreads, are linked with heart disease and death. But they can be completely eliminated and replaced with healthier oils and fats without changing the taste or cost of food. Elimination of industrially produced TFA from food is feasible, cost-effective and life-saving. A number of countries have already taken action to ban industrially produced TFA and protect their citizens. The 12 largest multinational food companies have also committed to eliminate industrially produced TFA from all their products by the year 2023. Yet action has been largely concentrated in wealthier countries, and countries with fewer resources continue to be disproportionately at risk of preventable deaths from TFA. This is unacceptable and unnecessary. Global elimination of industrially produced TFA is a WHO priority and a target in the 13th General Programme of Work, which guides our work through to 2023. WHO will support Member States to replace these harmful substances with healthier oils and fats. The WHO REPLACE action framework was launched in May 2018 and its accompanying six modules in May 2019 to guide governments to achieve this goal. Since then, Member States have made encouraging progress in eliminating TFA from their food supplies. But most countries remain unprotected from the harms of TFA. There is much more to be done to meet the goal of global elimination of industrially produced TFA from the entire global food supply in the next three years, by 2023. Dr Tedros Adhanom Ghebreyesus Director-General World Health Organization v
EXECUTIVE SUMMARY Intake of trans-fatty acids (TFA) is associated with increased risk of heart attacks and death from coronary heart disease. Replacing industrially produced TFA with healthier oils and fats is cost-effective and feasible, and can be done without changing the taste of food or its cost to the consumer. In May 2018, the World Health Organization (WHO) called for the global elimination of industrially produced TFA by 2023 and released the REPLACE action framework. The framework is a roadmap for countries to implement the prompt, complete and sustained elimination of industrially produced TFA from the food supply. In May 2019, WHO released six REPLACE modules, which provide practical, step-by-step implementation guidance to support governments. WHO recommends that countries adopt and implement one of two best-practice policy options for eliminating industrially produced TFA from the food supply. Countries are responding to this call to action, and the number of countries passing and implementing best-practice policies is growing. As of May 2020, best-practice TFA policies that either virtually eliminate industrially produced TFA or ban partially hydrogenated oils (PHO) are in effect for 589 million people in 14 countries (8% global population coverage). The number of countries with some form of mandatory TFA limits – either best-practice TFA policies or less restrictive TFA limits – has risen to 32 (32% global population coverage). Since the publication of the first progress report in May 2019, more than 40 countries have taken action to initiate or advance TFA policy discussions. Best-practice policies came into effect in Lithuania and Saudi Arabia, and were passed in Brazil and Turkey. India and Nigeria notified draft best-practice TFA policies for public comment. In October 2019, the 35 Member States of the WHO Regional Office for the Americas/Pan-American Health Organization unanimously approved a regional plan of action to eliminate industrially produced TFA by 2025. As well, civil society organizations have increased advocacy to support regulations and product reformulation. In its first two years, the global initiative to eliminate industrially produced TFA has produced encouraging results in some countries, but most still do not have policies in place to protect their citizens from the harmful effects of TFA. To meet the 2023 target, WHO recommends that countries take the following actions in the coming year. › Develop and implement best-practice policies to set TFA limits or to ban PHO. › Invest in monitoring mechanisms, such as laboratory capacity to measure TFA content in foods. › Advocate for regional or subregional regulations to expand the benefits of TFA policies. WHO will strengthen its support to countries working to eliminate TFA by the following activities: › Continue to provide technical support for building regulatory capacities to accelerate best-practice policy development, implementation and enforcement in countries. This includes strengthening laboratory capacity to assess TFA content in foods. › Disseminate country experiences, success stories and good practices, and recognize achievements by countries. › Undertake global advocacy through existing and newly developed frameworks and initiatives, such as the World Health Assembly, the United Nations Decade of Action on Nutrition, and the United Nations Food System Summit. WHO expects food and beverage industry groups to implement the commitments they have made to eliminate industrially produced TFA from product lines. WHO also expects major suppliers of oils and fats to step up to remove industrially produced TFA from the products that are sold to food manufacturers globally. vi i
I. INTRODUCTION Cardiovascular disease is the leading killer globally, causing an estimated 17.9 million deaths every year (Wang H et al., 2016). Based on the most recent global systematic evaluation of diet-related disease burden, dietary risks were responsible for 10 million deaths from cardiovascular disease among adults (Afshin et al., 2019). Intake of trans-fatty acids (TFA) is associated with increased risk of heart attacks and death from coronary heart disease (CHD) (WHO, 2019a). Although limited data are available on TFA intake globally, a recent report estimated that the 2017 global market volume of partially hydrogenated oils (PHO) – the main source of industrially produced TFA in food – was approximately 13.6 million tonnes (Persistence Market Research, 2018). Among various measures to tackle dietary risks, elimination of industrially produced TFA is a relatively straightforward, low-cost, one-time policy measure that is within reach and has significant long-term health benefits. Replacing industrially produced TFA with healthier oils and fats is feasible and cost-effective, and will save lives. TFA elimination has gained momentum as a global priority. As of May 2020, 32 countries have implemented mandatory TFA limits, covering 2.4 billion people (32% of the global population) (UN DESA, 2019). Of these, 14 countries – covering 589 million people (8% of the global population) – have implemented a best-practice TFA policy that either virtually eliminates industrially produced TFA or bans PHO. An additional 26 countries, with approximately 815 million people, have passed a best-practice TFA policy that will come into effect in the next two years. Regional regulations are an increasingly popular approach to the elimination of industrially produced TFA. In 2015, the Eurasian Economic Union (EAEU) became the first regional body to put into effect a TFA elimination policy. This was followed by the Gulf Cooperation Council (GCC) and the European Union (EU), which passed TFA limits in 2015 and 2019, respectively. In October 2019, countries in the Americas unanimously passed the Action Plan to Eliminate Trans-Fatty Acids from Industrial Production 2020–2025. Together, these four regional initiatives have the potential to protect more than 1.7 billion people in 73 countries. In many countries, civil society organizations are advocating for mandatory TFA limits and supporting governments to set these limits. The food industry is also becoming more receptive to replacing industrially produced TFA in their products with healthier oils and fats. In 2018, TFA elimination was identified as one of the priority targets in the World Health Organization (WHO) 13th General Programme of Work, which guides the five-year work of WHO in 2019–2023. Also in 2018, the REPLACE action package was launched to help countries eliminate industrially produced TFA from their food supplies. WHO released additional resources in 2019 to support country actions, including six implementation modules and a live policy tracking map – the TFA Country Score Card 1 – to monitor global progress towards the 2023 target. In 2020, WHO established a TFA indicator that records whether countries have adopted WHO best-practice policies for eliminating industrially produced TFA (WHO, 2020a). The TFA indicator is discussed in section II. Terms used in this report are described in Table 1.
TABLE 1. DEFINITIONS OF POLICY CATEGORIES Legislative or regulatory measures that limit industrially produced TFA in foods in all settings and are in line with the recommended approach. The two best- practice policies for TFA elimination are: "Best-practice TFA policy" 1 Mandatory national limit of 2 g of industrially produced TFA per 100 g of total fat in all foods; and 2 Mandatory national ban on the production or use of PHO as an ingredient in all foods. "Best-practice TFA policy Best-practice policies have been passed but have not yet come into effect. passed but not in effect" Legislative or regulatory measures that limit industrially produced TFA in foods in all settings, but are less restrictive than the recommended approach (e.g. 2% "Less restrictive TFA limits" limit for industrially produced TFA in oils and fats only; 2% limit for industrially produced TFA in oils and fats, and 5% limit in other foods; 5% limit for industrially produced TFA in oils and fats). A broader term that refers to both “best-practice TFA policy” and “less restrictive "Mandatory TFA limits" TFA limits”. Legislative or other measures that encourage consumers to make healthier choices about industrially produced TFA (e.g. mandatory declaration of TFA on "Other complementary measures" nutrition labels; front-of-pack labelling system that includes TFA; reformulation) or mandatory limits on industrially produced TFA in foods in specific settings (e.g. public institutions). "National policy commitment National policies, strategies or action plans that express a commitment to reduce to eliminate TFA" industrially produced TFA in the food supply. "Monitoring mechanism A mechanism that monitors the legislative or regulatory measures for mandatory for mandatory TFA limits" TFA limits. This progress report, the second since the 2018 launch of the REPLACE action package, aims to track and accelerate progress towards the goal of global elimination by 2023. The report: › Describes the current global, regional and national situations and changes during the past year (since May 2019); › Tracks progress of key policy outcomes and milestones; › Discusses challenges and opportunities for future action; › Highlights enablers and blockers of TFA elimination at the country level; and › Recommends strategic priorities for the next 12 months to achieve the 2023 target. In addition, this report highlights countries in each WHO region that have made significant policy advances in the past year. 2
II. GLOBAL PROGRESS 1. COUNTRY POLICIES CURRENT SITUATION Mandatory TFA policies are currently in effect for 2.4 billion people in 32 countries (32% of the global population in 2020). Of these, 14 countries (covering 589 million people – 8% of the global population) have best-practice policies, and two countries (Peru and Uruguay, covering 36 million people), which have less restrictive limits in place, have passed best-practice policies that will come into effect in the next two years. Another 26 countries, covering 779 million people, have also passed best-practice TFA policies that will come into effect within the next two years. Currently, 27 countries have other complementary measures in place, and 62 countries have a national policy, strategy or action plan in place that expresses a commitment to reduce TFA in the food supply. For the remaining 64 countries, there has either been no action to eliminate TFA or the status is unknown. Fig. 1 shows the status of TFA policy implementation around the world. The map is based on a country performance score card developed by WHO and data from the WHO Global database on the Implementation of Nutrition Action (GINA)2. The live map is constantly updated and accessible on the GINA and REPLACE webpages3. Annex 1 provides country-by-country information on the CHD burden attributable to TFA intake, and the status of TFA policies – both those that in effect and those that will shortly come into effect. The estimates on CHD burden in Annex 1 are provided by the Institute for Health Metrics and Evaluation (IHME) and are based on data from the Global Burden of Disease (GBD) study 2019, whereas the estimates in the 2019 progress report4 were based on data from GBD 2010. Several differences can be seen when the estimates in the current report are compared with those in the 2019 report. For example, the distribution of the TFA-attributable burden of CHD death appears to have become significantly narrower, and many countries appear to have substantially reduced the portion of CHD attributable to TFA. The rankings of countries have also shifted. These differences are mostly due to technical and methodological advances in estimating the burden of disease attributable to TFA intake. Changes made in methodologies used for the analysis in GBD 2019 are described in detail in Annex 2. Because of these advances in methodologies, it is considered that the estimates in Annex 1 more accurately reflect the reality of the worldwide CHD burden attributable to TFA. The changes in methodologies mean that estimates from the 2019 report and the current report cannot be directly compared. Although these estimates are currently the best available, there are some limitations. For example, the CHD burdens attributable to TFA in this report and the 2019 report are estimates based on modelling rather than actual measurements. Although an increasing number of countries now have data on TFA sales and consumption, there is still a data gap that needs to be filled by assumptions and extrapolations. Despite these issues, part of the change between GBD 2010 and GBD 2019 could also reflect actual changes as a result of policy achievements in countries that have introduced a TFA best-practice policy to virtually eliminate industrially produced TFA or ban PHO. TFA consumption has decreased in countries where the oil composition has changed as a result of reformulation after introduction of a best-practice policy. This reinforces the importance of countries pursuing regulations for TFA elimination. . 2 http://www.who.int/nutrition/gina/en/; GINA is an online database of validated information on countries’ policies and programme interventions relating to fortification, food labelling, marketing of breast-milk substitutes and nutrition (including TFA). 3 https://www.who.int/nutrition/topics/replace-transfat 4 https://apps.who.int/iris/bitstream/handle/10665/331300/9789241516440-eng.pdf 3
FIG. 1. TFA POLICY IMPLEMENTATION: MAP OF COUNTRY PERFORMANCE Best-practice TFA policies Best-practice TFA policy passed but not yet in effect Less restrictive TFA limits Other complementary measures National policy commitment to eliminate TFA Monitoring mechanism for mandatory TFA limits Note: The map is based on the data available in GINA (as of May 2020). A live and clickable Missing data version of the map is available on GINA: https://extranet.who.int/nutrition/gina/en/scorecard/TFA
As of May 2020, 14 countries have best-practice TFA policies in effect, and this number is projected to increase to at least 40 in 2022 (Fig. 2). Although good progress has been made, important disparities persist in policy coverage by region and country income level. Most policy actions to date, including those passed in 2019 and 2020, have been in higher-income countries and in the WHO regions of the Americas and Europe: best-practice TFA policies have been adopted by seven upper-middle-income countries5 and 33 high-income countries6 (Fig. 3). No low-income or lower-middle-income countries have adopted best-practice TFA policies. Supporting low- and middle-income countries to implement best-practice policies is critical to ensure that people in all countries benefit equally from protection from TFA in foods. FIG. 2. NUMBER OF COUNTRIES WITH BEST-PRACTICE TFA POLICY IMPLEMENTED, BY YEAR 45 39 40 40 35 Number of Countries 30 25 20 15 13 14 11 10 7 7 7 7 5 5 5 5 2 2 1 1 1 1 1 0 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 FIG. 3. NUMBER OF COUNTRIES WITH BEST-PRACTICE TFA POLICY PASSED OR IN EFFECT, BY INCOME STATUS 35 33 30 25 20 15 10 7 5 0 HIC UMIC LMIC LIC HIC: high-income countries; LIC: low-income countries; LMIC: lower-middle-income countries; UMIC: upper-middle-income countries 5 Brazil, Bulgaria, Peru, Romania, South Africa, Thailand, Turkey 6 Austria, Belgium, Canada, Chile, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Saudi Arabia, Slovakia, Slovenia, Spain, Sweden, United Kingdom, United States of America, Uruguay 6
In 2020, within the 13th General Programme of Work Results Framework, WHO developed an indicator that records whether countries have adopted WHO best-practice policies for eliminating industrially produced TFA. The indicator was based on estimated global averages (from IHME data) and represents the proportion of the population who are expected to reduce TFA intake to the level recommended by the WHO guideline (i.e. less than 1% of total energy intake) during the five years following policy implementation (WHO, 2020b). Table 2 shows the number of people with TFA intake exceeding the WHO recommended level of less than 1% of total energy intake, according to the year when countries’ best-practice policies took (or will take) effect. In the 40 countries with a best- practice TFA policy taking effect by 2022, nearly 280 million people are estimated to have an excessive TFA intake before or at the beginning of policy implementation and have the potential to benefit from the protection provided by the best-practice policy. It is estimated that currently 886 million people living in 143 countries without a best-practice TFA policy have TFA intake levels that exceed the WHO recommended level. These 886 million people could potentially be protected if these 143 countries introduced a best-practice policy. TABLE 2. NUMBER OF PEOPLE WITH TFA INTAKE EXCEEDING THE WHO RECOMMENDED LEVEL Number of people with Year of effect TFA intake exceeding of best-practice Countries WHO guideline at time TFA policy of implementation Before 2017 Denmark (2004); Austria (2009); Chile, Iceland, 2.0 million South Africa (2011); Hungary, Norway (2014) 2018 Canada, Latvia, Slovenia, United States of America 214 million 2019 Lithuania, Thailand 0.8 million 2020 Saudi Arabia 26,000 2021 (planned) Belgium, Brazil, Bulgaria, Croatia, Cyprus, Czech Republic, 61.7 million Estonia, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, Malta, Netherlands, Peru, Poland, Portugal, Romania, Slovakia, Spain, Sweden, Turkey, United Kingdom 2022 (planned) Uruguay 1,500 No best-practice Remaining 143 WHO Member States 886 million policy passed or in effect (not imminent) Note: 11 countries were not included due to missing data. NEW IN THE PAST YEAR Since the first annual progress report in May 2019, there has been significant progress in TFA elimination around the world (Table 3). Best-practice policies came into effect in Lithuania and Saudi Arabia, and a less restrictive TFA limit came into effect in Uruguay. In December 2019, a best-practice policy was passed in Brazil and will come into effect in July 2021. In May 2020, Turkey passed a best-practice TFA limit, which will take effect in 2021. Two countries notified draft best-practice TFA policies for public comment: India in August 2019, and Nigeria in January 2020. In October 2019, the 35 Member States of the Pan-American Health Organization (PAHO) unanimously approved the Plan of Action for the Elimination of Industrially Produced Trans-Fatty Acids 2020–2025 (PAHO, 2019). In the past year, there has been an encouraging trend towards countries adopting best-practice TFA policies rather than less restrictive limits. New policy measures passed and introduced have overwhelmingly followed best practice (passed in Brazil and Turkey; drafts introduced in India and Nigeria); and countries that previously had less restrictive measures are updating 7
policies to align with best practice (passed in Saudi Arabia; draft introduced in India). As well, Singapore officially announced plans to strengthen its existing less restrictive TFA limit (which applies to oils and fats only) to align with global best practice by implementing a ban on PHO (following Canada, Thailand and the United States as models) (Singapore Ministry of Health, 2019). In the next 12 months, WHO will continue supporting country adoption and implementation of best-practice TFA policies. WHO will also provide support to countries in strengthening their regulatory capacities to help accelerate implementation, compliance monitoring and enforcement of TFA policy actions. TABLE 3. PROGRESS IN MANDATORY TFA LIMITS SINCE MAY 2019 Best-practice TFA policy Less restrictive limits Came into effect Passed Draft policy proposed and Came into effect notified for public comment Lithuania Brazil Indiaa Uruguayb Saudi Arabia Turkey Nigeria a In 2011, India passed regulations that set a TFA limit of 10% in oils and fats, which was further reduced to 5% in 2015. In December 2018, the Food Safety and Standards Authority of India (FSSAI) proposed reducing this limit to 2% and eliminating industrially produced TFA in the food supply by 2022, a year ahead of the global target. In August 2019, the FSSAI proposed aligning India’s regulations with global best practice and notified for public comment draft regulations that apply the 2% TFA limit to all food products by January 2022. b Uruguay’s policy limits industrially produced TFA to 2% of the total fat content in oils and fats, and to 5% of the total fat in other foods. The policy took effect in November 2019. In a second implementation phase, by May 2022, the 2% limit will apply to all fats, oils and foods (best practice). 2. SUPPORT FOR REFORMULATION CURRENT SITUATION Elimination of industrially produced TFA requires the involvement of manufacturers of foods, edible oils and fats. In April 2019, Dr Tedros Adhanom Ghebreyesus, Director-General of WHO, issued a statement calling on fats, oils, and food and food service industries to reformulate foods to eliminate industrially produced TFA and increase replacement with alternatives low in saturated fatty acids (SFA) (WHO, 2019b). In May 2019, member companies of the International Food and Beverage Alliance (IFBA) committed to not exceeding 2 g of industrially produced TFA per 100 g of oils and fats in their products worldwide by 2023 (IFBA, 2019). IFBA companies account for approximately 13% of global packaged food sales (Alexander, Yach & Mensah, 2011). This means that manufacturers of almost 90% of packaged foods globally are not committed to eliminating industrially produced TFA. Suppliers of edible oils and fats may be even more instrumental than food manufacturers in eliminating industrially produced TFA from the global food supply. Relatively few suppliers of edible oils and fats serve all food manufacturing and service companies – from large multinationals to small and medium-sized enterprises. If industrially produced TFA are removed from oils and fats supplied to food manufacturing and service companies, they will be eliminated from all food products sold to consumers. To date, however, no suppliers have committed to eliminating industrially produced TFA from product lines. NEW IN THE PAST YEAR With funding from Resolve to Save Lives, the Global Alliance for Improved Nutrition (GAIN) and the Scaling Up Nutrition (SUN) Business Network initiated a project to provide technical support to small and medium-sized enterprises to reformulate product lines to remove industrially produced TFA (SUN Business Network, 2019). In 2019 and 2020, 25 small and medium-sized enterprises in Nigeria, and 15 in Pakistan received training from IFBA company experts, based on the needs and resources available in each country (GAIN, 2020). In 2019 and early 2020, a coalition of nongovernmental organizations (American Heart Association, NCD Alliance, Resolve to Save Lives, and World Heart Federation) sent letters to major food companies urging them to take action to protect the health of their consumers by removing industrially produced TFA from global product lines. In early 2020, discussions began on organizing a meeting for countries of the EAEU to create dialogue between the oils and fats industry and governments; the objectives were to use industry’s technical expertise to identify hurdles to achieving a food supply free from industrially produced TFA, and to build a technology roadmap for countries. However, the COVID-19 pandemic has resulted in postponement of this planned meeting. However, given the importance of this dialogue to move towards the target of 8
eliminating TFA by 2023, the potential to hold a virtual meeting before the end of 2020 is currently being considered. A priority for the next year will be to engage edible oils and fats suppliers to support a global supply chain that is free from industrially produced TFA, and to ensure that an appropriate accountability mechanism is in place. 3. GLOBAL RESOURCES AND SUPPORT FOR POLICY ACTION CURRENT SITUATION WHO is committed to supporting countries to implement the actions of the REPLACE action package. The complete REPLACE action package, including a technical framework and comprehensive implementation resources, is available on the REPLACE webpage.7 Ensuring capacity to monitor compliance and enforce TFA regulations is critical to maximizing public health benefits. Some countries (generally higher-income countries) have mandatory labelling – that is, a TFA declaration on nutrient facts panels and/ or PHO on the ingredients list – that should ensure compliance with regulations. However, even when labelling requirements are in place, it is important for countries to be able to confirm, through laboratory testing, that companies are complying with the information on the labels. Many other (generally lower-resourced countries) do not have labelling requirements in place and will need to rely on some laboratory testing of TFA levels to monitor compliance. Further, labelling is not a viable compliance monitoring mechanism in countries where sources of TFA include unpackaged foods. A lack of in-country laboratory capacity for measurement of TFA in foods, especially in lower-resourced countries, can be a barrier to enforcement. To support country assessments of TFA in foods, WHO convened an expert consultation in October 2018 and released global surveillance protocols in May 2019. These protocols (available on the REPLACE webpage8) can be adapted for measuring TFA levels in national food supplies in a range of settings. NEW IN THE PAST YEAR To support countries in designing and implementing best-practice TFA policies, a regulatory and legal capacity-building course was developed. The interactive training was delivered in June 2019 for countries in the Eastern Mediterranean Region, and in July 2019 for countries in the Americas Region. To better understand the laboratory needs in countries, an interlaboratory study (“ring trial”) on measurement of TFA and other fatty acids in selected foods by gas chromatography was undertaken. Fourteen laboratories, representing all WHO regions, are participating in the study, which aimed to assess the level of agreement of results among laboratories. Full analysis of results is under way. The global laboratory protocol for measuring TFA in food have been revised, based on the preliminary findings from this study, to make them more usable for countries. In many countries, civil society organizations and other nongovernmental organizations have become active around TFA elimination. Groups have developed resources to support REPLACE implementation and policy action in countries, including advocacy briefs, food sampling protocols for measuring TFA, and country case studies (available in the LINKS cardiovascular health toolkit section).9 A Knowledge Exchange Network was established in 2019 by NCD Alliance, providing a virtual platform for civil society organizations working on TFA elimination to share experiences, successes and challenges. In the next year, WHO will accelerate efforts in providing Member States with technical support to strengthen their regulatory and legal capacities for implementing policies to eliminate TFA from their food supplies. WHO also plans to publish the ring trial results and will explore the possibility of identifying laboratories that could become regional hubs for TFA testing in foods. 7 https://www.who.int/nutrition/topics/replace-transfat 8 https://www.who.int/nutrition/topics/replace-transfat 9 https://linkscommunity.org/toolkit/trans-fat-elimination; LINKS is a collaborative effort of WHO, the United States Centers for Disease Control and Prevention through the CDC Foundation, and Resolve to Save Lives (an initiative of Vital Strategies). 9
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III. PROGRESS BY REGION 1. AFRICA CURRENT SITUATION The African Region (see Table 4) continues to have only a small number of countries with mandatory TFA limits or other complementary measures. South Africa has had best-practice mandatory TFA limits in foods, oils and fats since 2011. Fourteen countries have adopted national plans on nutrition or noncommunicable diseases (NCDs) that include goals or strategies to eliminate industrially produced TFA. TABLE 4. SUMMARY OF THE TFA POLICY SITUATION IN THE AFRICAN REGION National policy Other Less Best- Best- commitment to complementary restrictive practice practice eliminate TFA measures TFA limits TFA TFA policy Monitoring policy passed mechanism but not in for effect mandatory (as of May TFA limits 2020) Algeria, Benin, Ethiopia South South Africa Botswana, Cabo Africa Verde, Chad, Côte d’Ivoire, Eswatini, Ghana, Kenya, Mauritius, Namibia, Nigeria, Seychelles, Zambia NEW IN THE PAST YEAR In the past 12 months, TFA policy discussions have begun in several key countries. In Nigeria, a technical working group was established in 2018 to support the Ministry of Health and the Nigerian National Agency for Food and Drug Administration and Control (NAFDAC) in developing the evidence and recommendations around the need for TFA limits. In 2020, NAFDAC notified a draft best-practice TFA policy that limits TFA to 2% of oils and fats in all oils, fats and foods. The policy experience in Nigeria is described in Box 1. In Ethiopia, in March 2020, parliament passed an excise tax on food products that are known to increase the risk of diabetes and heart disease, including sugar-sweetened beverages, and oils and fats with high levels of SFA or TFA. Under the new tax law, margarine with more than 40% SFA, or more than 0.5% TFA, will be taxed at 50%; and partially or wholly hydrogenated oils and fats with more than 40% SFA, or more than 0.5% TFA, will be taxed at 40%, as will oils and fats whose SFA content is not labelled or is unable to be determined from the label. In Uganda, the Ministry of Health began developing the Uganda National Food Control Strategic Plan; the situation analysis included a label review to assess TFA levels in popular food products. Civil society groups in Africa are activating around TFA elimination. LINKS awardees in Tanzania (Muhimbili University of Health and Allied Sciences) and Kenya (International Institute for Legislative Affairs) have begun projects to assess the amount of TFA in the national food supplies, so that they can promote best-practice policies, and replacement with healthier oils and fats. Because many countries in the African Region have limited resources and regulatory capacities, and the political priority to support TFA elimination is also limited, working at the level of regional trading blocs as entry points may help to accelerate progress in the region. This will be further explored in the next 12 months. Meanwhile, interested countries will continue to be supported in implementing actions to eliminate TFA, including through development of TFA elimination policies. A regional capacity-building workshop was planned for 2020 to strengthen regulatory capacities of national policy-makers in the region. However, as a result of the COVID-19 pandemic, it has been postponed, perhaps to 2021. Some parts of the planned capacity-building training may be conducted virtually while waiting for the more detailed face-to-face training workshop. 11
Box 1. Policy experience in Nigeria Just a year and half after first taking on TFA elimination, the Nigerian Government drafted, announced and notified for public comment a best-practice TFA policy in January 2020; this is an encouraging timeline that underscores the feasibility of the WHO goal of global elimination by 2023. Passage of the best-practice policy is expected by the end of 2020. The success in Nigeria was due to political will within the government – including at NAFDAC, the Federal Ministry of Health and other key agencies – and the central role of civil society in advocating, convening stakeholders and providing legal support on policy provisions throughout the policy process. POLICY DEVELOPMENT: In June 2018, NAFDAC proposed fats and oils regulations without any mention of TFA or PHO. Through media monitoring, civil society groups identified this as an opportunity to include TFA limits. In August 2018, the Nigerian Medical Association (NMA) successfully appealed to NAFDAC to extend the deadline for public comment on the proposed fats and oils regulations. In September 2018, the NMA discussed the importance of TFA elimination with the Minister of Health. At the minister’s request, the NMA convened a technical working group on TFA elimination. Participants included representatives of key government agencies, including the Federal Ministry of Health, the Ministry of Budget and National Planning, NAFDAC, the Standards Organization of Nigeria, the Consumer Protection Council and the Nigerian Bureau of Statistics. It also included representatives from WHO and from civil society organizations, including the Nigerian Heart Foundation, the Nutrition Society of Nigeria, the Nigerian Cardiac Society and the Nigerian Council for Women. With guidance from the technical working group on international best practices for TFA elimination, NAFDAC, in April 2019, published revised fats and oils regulations that would limit TFA content to 2% of oils and fats. The agency also released regulations on pre-packaged food labelling that address TFA and other food components. Civil society proposed areas for improvement to ensure that the policy would meet global best practices and maximize health benefits. At a strategic meeting with the Acting Minister of Health and civil society advocates in June 2019, the permanent secretary of the Federal Ministry of Health agreed to champion TFA elimination. Understanding the current burden of TFA in the food supply and establishing a baseline for ongoing monitoring were identified as priorities. The following month, research experts from the Global Health Advocacy Incubator trained Nigerian researchers in collecting food samples for TFA testing. NAFDAC also invested in laboratory equipment and staff training to analyse TFA in foods. In August 2019, NAFDAC’s Director General met with WHO and civil society advocates to discuss further improvements to the agency’s fats and oils regulations. This led to the reopening of the regulations for public evaluation. After a period of intense campaigning by civil society advocates to raise public awareness of TFA health harms and build support for TFA regulations, NAFDAC released the revised regulations on fats and oils, as well as on pre-packaged foods, for a 60-day public comment period in January 2020. The updated regulations on fats and oils include a best-practice limit on TFA. As the Nigerian Government, WHO and civil society worked to advance the regulations, industry also activated around the issue of TFA elimination. In October 2019, an orientation workshop on reformulation of products high in TFA was conducted for small and medium-sized companies. The show of support from local industry reinforced NAFDAC’s commitment to implementing the REPLACE action package. POLICY IMPLEMENTATION: When regulations are finalized and come into effect (expected to occur in 2021), NAFDAC will design an implementation and enforcement strategy. 12
2. AMERICAS CURRENT SITUATION The Americas Region (see Table 5) continues to make swift progress towards eliminating industrially produced TFA. Before the release of the REPLACE action framework in 2018, mandatory TFA limits were already in place in four countries in the region. Chile has had a best-practice 2% limit for industrially produced TFA in oils and fats that has applied to all foods since 2011; Argentina (2014), Colombia (2013) and Ecuador (2014) all have limits of 2% in oils and fats, and 5% of total fat in all foods. In 2018, complete bans on PHO came into effect in Canada and the United States, and Peru established a TFA limit of 2% in vegetable oils and margarines, and 5% of total fat in all foods. In 2021, Peru will implement a second phase of the regulations, banning PHO completely. The policy experience in Peru is described in Box 2. TABLE 5. SUMMARY OF THE TFA POLICY SITUATION IN THE AMERICAS REGION National policy Other Less Best- Best- commitment to complementary restrictive practice practice eliminate TFA measures TFA limits TFA TFA policy Monitoring policy passed mechanism but not in for effect mandatory (as of May TFA limits 2020) Antigua and Barbuda, Bolivia (Plurinational Argentina, Canada, Brazila, Peru, Argentina, Bahamas, Barbados, State of), Brazil, El Colombia, Chile, Uruguay Canada, Belize, Costa Rica, Salvador, Mexico, Ecuador, United Chile, Dominican Republic, Paraguay Peru, States Colombia, Grenada, Guatemala, Uruguaya Ecuador, Guyana, Jamaica, Peru, Saint Kitts and Nevis, Saint Lucia, Saint United States, Vincent and the Uruguay Grenadines, Suriname, Trinidad and Tobago, Venezuela a New since May 2019. NEW IN THE PAST YEAR In 2019, Uruguay implemented regulations limiting TFA to 2% in vegetable oils and margarines, and 5% in all other foods; in 2022, the 2% limit will be extended to apply to all foods. In December 2019, Brazil became the sixth country in the Americas Region to pass a best-practice policy (following Canada, Chile, Peru, the United States and Uruguay). Brazil’s National Agency of Sanitary Surveillance (ANVISA) adopted regulations setting a 2% limit for industrially produced TFA in all oils and foods (effective July 2021), and banning all PHO (effective January 2023). The policy experience in Brazil is described in Box 3. In October 2019, Member States in the Americas Region unanimously approved a new plan to reduce cardiovascular disease by eliminating industrially produced TFA from foods by 2025. The Action Plan to Eliminate Trans-Fatty Acids from Industrial Production 2020–2025, approved by the 57th Directing Council of PAHO, promotes best-practice TFA policies (PAHO, 2019). In the next 12 months, country-level implementation of the action plan will be a priority in the region. 13
Box 2. Policy experience in Peru Since 2018, mandatory limits in Peru have capped TFA content at 2% in vegetable oils and fats, and 5% in other processed foods. A best-practice PHO ban is scheduled to take effect in 2021. PAHO’s and WHO’s recommendations on TFA, Chile’s policy implementation and enforcement success, and a PHO ban implemented in the United States and Canada have inspired the adoption of a best-practice TFA elimination policy in Peru. POLICY DEVELOPMENT: During the past 10 years, Peru has passed several policies in support of a food supply free from industrially produced TFA. These were motivated by the obligation of the state to promote and protect public health, and by the increasing prevalence of diet-related NCDs, including TFA-related NCDs, and deaths caused by such diseases. The Peruvian Government took its first step towards protecting the people of Peru from TFA in 2010, when the Consumer Defense and Protection Code began requiring declaration of TFA content on food nutrient labels. In 2013, a new law on the promotion of healthy foods for children and adolescents was passed, requiring both front-of-pack warning labels (including on TFA) and issuance of regulations for a gradual reduction of industrially produced TFA in all packaged foods, whether nationally produced or imported, until complete elimination. In July 2016, a follow-up regulation specified a five-year, two-phase process and time frame for elimination of industrially produced TFA. The first phase came into effect in mid-2018, mandating that TFA in all fats, vegetable oils and margarines oils could no longer exceed 2% of total fat. For all other processed foods and non-alcoholic beverages, the TFA limit was 5%. Five years after signing of the regulation (2021), a complete ban on PHO will become effective, and the limit of industrially produced TFA from non-PHO sources, such as oil refining and processing, will be 2% of fats for all products. In early 2018, another follow-up regulation stipulated the precise requirements for the prominent front-of-pack warning labels and for their use in advertising of affected products. Although industry and related actors opposed these sets of regulations and tried to delay their implementation, civil society helped move the process forward by advancing arguments about the proven feasibility of these approaches, the need to protect public health, and the absolute priority of public health over trade and commerce. Since mid-2019, all products containing any amount of TFA must present a front-of-pack label indicating “CONTAINS TFA”; all related advertisements for products must also feature the warning. Peru was the first country to implement such a policy. POLICY IMPLEMENTATION: Compliance with the regulations is monitored through verification of ingredients lists. For imported foods, compliance is enforced through mandatory pre-importation registration, certificates of analysis and importer certification. The burden is on the food industry to demonstrate that the nutrition content of products being imported is in line with the standards in Peru. The National Institute for the Defence of Competition and the Protection of Intellectual Property (Instituto Nacional de Defensa de la Competencia y de la Protección de la Propiedad Intelectual) monitors compliance with the front-of-pack labelling requirement, and reviews labels in supermarkets and at other points of sale; compliance with the regulations is monitored by the General Directorate of Environmental Health (Dirección General de Salud Ambiental). Penalties for noncompliance with the policy include a ban on sale of the noncompliant product, a fine, closure of the establishment and withdrawal of the health certificate. Consumers and civil society also contribute to monitoring via a mechanism for filing complaints about violations. To support this monitoring activity, civil society, together with academia, PAHO and WHO, the Ministry of Health and other government entities have formed a standing working group, which meets periodically to evaluate and ensure proper implementation of the healthy food law. Pre-regulation studies were carried out using a combination of review of ingredients lists for products on the market, and laboratory analyses to verify accuracy of ingredients lists and amounts of TFA. Early post-regulation market studies have shown that front-of-pack signs have resulted in a reduction in sales of products containing TFA and/or excessive amounts of sugars, SFA and/or sodium (Kantar World Panel, 2019). 14
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Box 3. Policy experience in Brazil Serious efforts to address the negative consequences of industrially produced TFA in foods began in Brazil in the early 2000s. Participation in the South American trade bloc Mercosur (Mercado Común del Sur) spurred Brazil’s initial policy action, when Mercosur made labelling for TFA on packaged foods mandatory in 2003. During the past 15 years, Brazil has participated in regional working groups, made pledges and conducted assessments, culminating in the passage of best-practice TFA regulations in December 2019. The regulations will limit TFA to 2% of total fat in all foods by July 2021 and ban PHO by January 2023. Political will to assess and act on the burden of TFA in Brazil, and an activated civil society were key influencers of Brazil’s policy success towards TFA elimination. POLICY DEVELOPMENT: Brazil was one of the first countries to take policy action against the well-documented harms of TFA. In 2003, the Brazilian National Agency of Sanitary Surveillance (Agência Nacional de Vigilância Sanitária – ANVISA) adopted a Mercosur resolution requiring food manufacturers to report TFA content per serving on the nutrition facts label, unless the amount is 0.2 g per portion or less; in these cases, companies may make claims of “zero trans” or “trans free” on the packaging (ANVISA, 2003). In 2007, Brazil’s Ministry of Health signed a cooperation agreement with the Brazilian Association of Food Industries to promote healthy lifestyles and nutritional diets, including reducing TFA in processed foods (Brasil Ministério da Saúde, 2008). In June 2008, the Ministry of Health and several food and cooking oil industry representatives signed the Trans Fat Free Americas declaration of Rio de Janeiro, pledging to limit industrially produced TFA to 2% of total fat in oils and margarines, and to 5% in processed foods (PAHO, 2008). Despite these efforts, consumption of TFA in Brazil exceeded the limit recommended by WHO (maximum of 1% of total energy intake). In 2008–2009, the first Brazilian National Dietary Survey assessed the burden of TFA consumption in Brazil. Results revealed that average daily TFA intake was 1.4% of total energy, and that a diet consisting of ultra- processed foods contained eight times more TFA than one made up of fresh and minimally processed foods (Louzada et al., 2015). There was a clear need to take further action. In 2009, the Ministry of Education approved a resolution to limit TFA in school meal programmes to 1% of total energy. In May 2017, legislation was introduced to ban the use of PHO in the manufacturing of food. ANVISA was allowed to grant exceptions based on technical justifications. The legislation was approved by the Senate and referred to the House of Deputies (Câmara dos Deputados, 2017). In March 2018, ANVISA announced its intention to examine regulatory options on TFA (ANVISA, 2018). In May 2018, ANVISA hosted a stakeholder meeting to review available TFA research, following the call by WHO to eliminate industrially produced TFA from the global food supply. ANVISA took several actions over the following months, including releasing a technical report summarizing information on TFA in Brazil, hosting a stakeholder meeting on TFA elimination with civil society and industry representatives, and releasing a timetable for addressing TFA in foods. In July 2019, ANVISA’s board of directors released its justification for regulating TFA in foods and approved the launch of a public consultation process on the policy proposal, from 7 August to 7 October 2019. In parallel, civil society advocates had begun to activate around TFA elimination in early 2019. Advocates assessed ways to support the adoption of TFA policies and strengthen ANVISA’s role in regulating TFA in foods, and met with ANVISA representatives advocating for TFA policies. The Brazilian Association of Nutrition (Associação Brasileira de Nutrição – ASBRAN) was the face of civil society advocates working for a TFA policy in Brazil, and coordinated public engagement around ANVISA’s consultation process. ANVISA’s public consultation received more than 1200 comments, of which 90% supported the agency’s proposal to regulate TFA in foods. Following a stakeholder meeting in November 2020, ANVISA’s board of directors approved a plan to limit TFA to 2% of total fat in all foods by July 2021, and ban PHO from January 2023. On 26 December 2019, ANVISA’s TFA regulation (RDC 332/2019) was published in the Official Gazette. POLICY IMPLEMENTATION: ANVISA is now developing a strategy for policy monitoring and enforcement. Civil society continues to provide technical support in designing this strategy. 16
3. EASTERN MEDITERRANEAN CURRENT SITUATION The Eastern Mediterranean Region has had some of the highest TFA intake globally (Wang Q et al., 2016). Iran was the first country in the region to regulate TFA, with a 2% limit in oils and fats that became effective in 2016. In 2015, the Gulf Cooperation Council (GCC) approved TFA limits of 2% of total fat in vegetable oils and soft spreadable margarines, and 5% of total fat in other foods. GCC Member States (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and United Arab Emirates) must each approve implementation of the regulation before it can come into effect in the country. Of the GCC countries, Bahrain, Kuwait and Saudi Arabia have implemented the regulation, which took effect in 2016, 2017 and 2017, respectively; the implementation process has been initiated in Oman and Qatar. Table 6 summarizes the TFA policy situation in the Eastern Mediterranean Region. TABLE 6. SUMMARY OF THE TFA POLICY SITUATION IN THE EASTERN MEDITERRANEAN REGION National Other Less Best- Best- policy complementary restrictive practice practice commitment measures TFA limits TFA policy TFA policy Monitoring to eliminate passed mechanism TFA but not in for effect mandatory (as of May TFA limits 2020) Afghanistan, Jordan, Oman, Bahrain, Saudi Arabiaa Saudi Arabia Egypt, Lebanon, Pakistan, Tunisia Iran (Islamic Morocco, Qatar, Republic of), United Arab Kuwait Emirates a New since May 2019. NEW IN THE PAST YEAR During the past year, interest in TFA elimination in the region has increased. In January 2020, Saudi Arabia implemented a second phase of its TFA policy, banning PHO and becoming the first country in the region with a best-practice policy. The policy experience in Saudi Arabia is described in Box 4. In early 2019, WHO collaborated with the governments of Egypt and Pakistan to assess TFA sources and the levels of TFA in foods (WHO, 2019c). In Pakistan, the Ministry of Health established a Technical Working Group on TFA in September 2019. The group is co-led by the Ministry of Health and WHO, and is working to build support for, and draft, a best-practice policy. In June 2019, the WHO Regional Office for the Eastern Mediterranean hosted key government representatives from 15 countries (Bahrain, Iraq, Jordan, Kuwait, Lebanon, Libya, Morocco, Oman, Palestine, Pakistan, Qatar, Saudi Arabia, Sudan, Syria, Tunisia) for a legal and regulatory capacity-building workshop. At the workshop, countries learned about best-practice approaches for TFA elimination and began identifying key elements of a regulation for effective elimination in their countries. A key challenge raised during the workshop is the lack of laboratory capacity in the region to conduct TFA testing in foods, which is necessary for monitoring compliance with TFA limits. In the next 12 months, WHO will continue to support the development of best-practice policies in countries and laboratory capacity-building for TFA analysis in the region. 17
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